STS Privacy Policy

We at STS care about data protection and your privacy. In this privacy policy, we want to inform you about how we process your personal data and what rights you have when you use our website. Personal data is all information that relates to you, for example name and email addresses.

We mainly process your personal data for the following purposes:

• to market our services and send newsletters or brochures to you on your request;
• to answer your questions about our services;
• to sign you up to attend one of our meetings;
• to administer your interest application for High School, to become a host family or to become an ambassador; and
• to make a preliminary assessment of your application to participate in one of our trips.

You have several rights according to data protection law. For example you always have a right to object against marketing. You can also read about how to affect our processing of your personal data – what rights you have.

Do you want to know more? Please read our detailed explanations below. Below you can read more about how, why and for how long a period we process your personal data.

Summary of contents

• A policy for your privacy – Intro & Summary
• Who is responsible for the processing of your personal data?
• Who provides us with your personal data?
• Do you have to provide your personal data? What happens if you don´t?
• Who can gain access to your personal data?
• Do we transfer your personal data to an area outside of the EU or the EEA?
• How can you affect our processing of your personal data?
• Information about the personal data that we process, the purposes for why we process the data, our legal basis for the processing and the duration of the processing
• Our processing when we send you information and marketing about our services
• Our processing when we answer your questions
• Our processing when you sign up to attend a meeting with us
• Our processing when you send us an interest application to High School
• Our processing when you send us an interest application to become a host family or ambassador
• Our processing, when you send us an application to one of our services

Who is responsible for the processing of your personal data?

STS Education Group AB, Swedish company registration number 559251-3112, (“STS”), is responsible, in capacity of controller, for the processing of your personal data when STS processes your data for STS’s own purposes, as further described below.
This policy explains how we process your personal data when you use our website. If you proceed to travel with us or if you become one of our host families or ambassadors after you have used our website, we will give you further information in a separate policy about how we further process your personal data. If you want to know more about that now, you can contact us.

If you have any questions regarding our processing of your personal data – or if you want to exercise any of your rights as described in the section of this policy called “How can you affect our processing of your personal data?” – please contact us. STS has the following contact information: Address: Vasagatan 7, 411 24 Gothenburg, Sweden, telephone number: +46 771-20 20 40 and email address: dataprotection@sts.se.

Who provides us with your personal data?

You or your parent or legal guardian have provided all the personal data that we process about you who use our website.
All personal data that we process about you, who are a parent or legal guardian, have been provided to us by yourself.
Do you have to provide your personal data? What happens if you don´t?

Generally, it is always you who decide what personal data you want to share with us. Nonetheless, some of your personal data is necessary for us to process to be able to carry out our contract and fulfill our commitments to you. This is the case when we act on your request, e.g. when we send you a brochure that you have ordered. If you do not provide us with the necessary information, we will not be able to fulfill our commitments towards you according to your request, i.e. our agreement.

Who can gain access to your personal data?

Your personal data is mainly only processed by STS. However, your personal data will be shared with others when this is necessary in order to deliver brochures or newsletters that you have requested, or to perform our contract.

Here are the details of how we share your personal data:

• We share your personal data with our IT-suppliers (external and internal), as well as any other suppliers. Your personal data is only shared to the extent necessary for the suppliers to perform their contractual obligations in relation to STS, such as performance of IT-support; and
• If you order brochures from us, we will share your personal data with companies that print and deliver the brochure on our behalf.

How can you affect our processing of your personal data?

According to data protection legislation, you are entitled to a variety of rights to affect our processing of your personal data. Read more below.

Right to withdraw consent and to object to processing

You have a right to, wholly or partly, withdraw a given consent for the processing of your personal data. Your withdrawal will have effect from the time of your withdrawal.

You have the right to object to our processing of your personal data. You have always a right to object to marketing from us, such as newsletters.

The right to object generally is applicable when the processing is based on a balance of legitimate interests. Read more about what this means in the tables below. In some cases, however, the right to object does not exist (e.g. since we must store your personal data). If we can show compelling legitimate reasons for the processing that weigh heavier than your interests and fundamental rights or if it is for the purpose of determining, practicing or defending legal claims you do never have a right to object to the processing.

Right to access

You have the right to obtain confirmation as to whether or not we are processing personal data concerning you. You can gain access to the personal data and obtain a copy of the personal data processed by us.

Right to rectification

You have a right to obtain rectification of any inaccurate personal data concerning you and to ask us to have incomplete personal data completed.

Right to erasure (“the right to be forgotten”) and restriction of processing
Under certain circumstances, you have a right to request erasure of your personal data. This is the case for example where the personal data is no longer necessary for the purposes for which they were collected or otherwise processed, or you withdraw your consent on which the processing is based on and where there is no other legal ground for continuance of the processing.
You also have a right to request that STS restrict its processing of your personal data. That is the case for example when the accuracy of the personal data is contested by you, or the processing is unlawful, and you oppose the erasure of the personal data and instead requests restriction of its use.

Right to lodge a complaint to a supervisory authority

You always have the right to lodge a complaint with a supervisory authority.
You may do this in the EU/EEA member state of your habitual residence, place of work or of an alleged infringement of the applicable data protection laws. In New Zealand, the supervisory authority is The Privacy Commissioner’s Office. This right is without prejudice to any other administrative or judicial remedy.

Right to data portability

You have a right to ask us to transfer certain parts of your personal data we have about you to another company (data portability) in a structured commonly used, machine-readable and interoperable format.
This right applies to personal data that you have provided us if:

• The processing is based on consent or on a contract; and
• The processing is carried out by automated means.

In exercising your right to data portability, you have the right to have personal data transmitted directly from STS to another controller, where technically feasible.

Information about the personal data that we process, the purposes for why we process the data, our legal basis for the processing and the duration of the processing

All processing of your personal data is done for the purpose of sending you the newsletters and brochures that you request from us, answering your questions and signing you up to meetings with us. Furthermore, our purpose is to administer interest applications from you to become a host family or ambassador, administer applications regarding our trips and to market our services towards you.

You can read the details of how we process your personal data in the tables below.

Our processing when we send you information and marketing about our services

For which purposes do we process your personal data?	What personal data do we process?	What is our legal basis for processing your personal data?	For how long will we process your personal data for each purpose?
To send you newsletters that you have signed up to.	Your email address. In order to determine which marketing that is relevant for you, we process information that you have shared with us or that we collect from you when using our website.	Your consent.	Until you withdraw your consent or unsubscribe from our newsletters and marketing.
To send you the brochure that you have ordered.	Your name, phone number and email address. If you want us to post the brochure to your home address, we also process your postal address.	Processing is necessary for the performance of our contract, i.e. to send you the brochure that you have ordered.	Until you have received the brochure.
To be able to market our services towards you after we have been in contact, for example after you have filled in any of our forms (see above and below).	Your name, contact information and other information that you have shared with us when filling out one of our forms.	Your consent.	Until you withdraw your consent or unsubscribe from our marketing.

Our processing when we answer your questions

For which purposes do we process your personal data?	What personal data do we process?	What is our legal basis for processing your personal data?	How long will we process your personal data for each purpose?
To answer the questions that you have asked us by email, chat, phone or when filling in any of our forms (see below). Especially when you fill in our form “let us call you”.	Information that you provide to us when asking questions, such as your name and your question. If you ask us to call you, we will process your name and phone number. If you send us an email with your questions, we will process your email address.	Processing is necessary for the performance of our contract, i.e. in order for us to be able to answer your questions as requested.	For three (3) months after we have answered your questions, so that you can get back to us with further questions or wanting to move forward with an application.

Our processing when you sign up to attend a meeting with us

For which purposes do we process your personal data?	What personal data do we process?	What is our legal basis for processing your personal data?	How long will we process your personal data for each purpose?
In order for you to sign up for and attend our Information Meeting, Online Meeting or personal meeting with us.	Your name, phone number and email address.	Processing is necessary for the performance of our contract, i.e. so you can attend a meeting.	Until the meeting is completed.
To give information that you need before the meeting.	Your name, phone number, email address and other information that you have shared with us.	Processing is necessary for the performance of our contract, i.e. to make sure you have the relevant information when attending one of our meetings.	Until the meeting is completed.

Our processing when you send us an interest application to High School

For which purposes do we process your personal data?	What personal data do we process?	What is our legal basis for processing your personal data?	How long will we process your personal data for each purpose?
To process your interest application to the High School programme.	Your name, nationality, phone number, e-mail address, postal address and birth date. If you apply for High School abroad, we also process information about who your parent or legal guardian is, which relationship you have and your parent or legal guardians phone number and email address. We also process information about you that you share with us, i.e. when and where and which programme you are interested in.	Processing is necessary in order to take steps, at your request, prior to entering into a contract, e.g. to contact you for a free consultation.	Until we have processed your interest application.
To be able to continue your application process, i.e. to contact you about your application.	Your name and contact information.	Processing is necessary in order to take steps, at your request, prior to entering into a contract.	Until you have decided not to move forward with your application, or until you have taken the next step in your application process.

Our processing when you send us an interest application to become a host family or ambassador

For which purposes do we process your personal data?	What personal data do we process?	What is our legal basis for processing your personal data?	How long time do we process your personal data for each purpose?
To process your interest application to become one of our host families.	Your name, phone number and email address. We also process information about you that you share with us when filling out the form.	Processing is necessary in order to take steps, at your request, prior to entering into a contract.	Until we have processed the application.
To process your interest application to become an ambassador.	Your name, phone number, email address, nationality, year of birth and information about your previous trips with us. We also process information about you that you share with us when motivating why you want to become an ambassador.	Processing is necessary in order to take steps, at your request, prior to entering into a contract.	Until we have processed your interest application.
To be able to continue your application process, i.e. to contact you about your application.	Your name and contact information.	Processing is necessary in order to take steps, at your request, prior to entering into a contract.	Until you have decided not to move forward with your application, or until you have taken the next step in your application process.

Our processing, when you send us an application to one of our services

For which purposes do we process your personal data?	What personal data do we process?	What is our legal basis for processing your personal data?	How long will we process your personal data for each purpose?
To make a preliminary assessment of your application regarding the High School programme. This includes to process your gender in order to be able to place you in a suitable accommodation when moving forward with your application.	Your name, nationality, phone number, email address, postal address and date of birth. If another participant has asked to stay with you, we will also process your name for that purpose. If you sign up to High School we also process information about who your parent or legal guardian is, which relationship you have and your parent or legal guardians phone number and email address.	Processing is necessary in order to take steps, at your request, prior to entering into a contract, i.e. to process your application and to determine if you are able to travel with us.	Until we have processed your application.
To be able to continue your application process, i.e. to contact you about your application.	Your name and contact information.	Processing is necessary in order to take steps, at your request, prior to entering into a contract.	Until you have decided not to move forward with your application, or until you have taken the next step in your application process.

This policy was adopted by STS on 23 May 2019